G.R. No. 191902 July 30, 2019
MARINO B. DAANG, Petitioner vs. SKIPPERS UNITED PACIFIC, INC. and COMMERCIAL S.A., Respondents

FACTS

Petitioner Marino B. Daang was hired as a chief cook. On May 15, 2007, he strained his back while lifting a heavy bag of flour. After medical treatment and repatriation, the company-designated physician declared him fit to work on July 2, 2007, with the advice to refrain from lifting heavy objects. Daang executed a Receipt and Release for sickness benefits on July 14, 2007. He later consulted a private physician who declared him with a Grade 6 (50%) permanent disability. Daang filed a complaint for disability benefits. The Labor Arbiter and the National Labor Relations Commission (NLRC) ruled in his favor, awarding US$60,000. The Court of Appeals reversed, giving credence to the company doctor’s fit-to-work assessment and upholding the validity of the Release and Receipt.
Pending resolution of his petition before the Supreme Court, Daang filed an urgent manifestation. He revealed that on March 10, 2009, the parties had executed a “Conditional Satisfaction of Judgment” before the NLRC to prevent imminent execution. Under this agreement, Daang received ₱2,985,129.00 as conditional payment of the LA’s award. He executed a notarized affidavit, approved by the Labor Arbiter, committing not to file any further complaint and agreeing to return the payment should the NLRC decision in his favor be reversed.

ISSUE

Whether the execution of the Conditional Satisfaction of Judgment and the receipt of payment by Daang rendered the case moot and academic.

RULING

Yes. The Supreme Court granted Daang’s motion and declared the case moot and academic. The Court applied the precedent in Hernandez v. Crossworld Marine Services, Inc., which held that a conditional settlement of a judgment award, if highly prejudicial to the employee, is treated as a voluntary settlement that operates as a final satisfaction in the employee’s favor. Here, Daang received the full monetary award granted by the LA and NLRC. In his accompanying affidavit, he committed to no longer file any complaint against the respondents. This constituted a complete satisfaction of his claims.
The Court rejected the respondents’ argument that the settlement was merely a protective measure against execution. Respondents were not compelled to pay immediately, as they had already posted an appeal bond to stay execution. By voluntarily paying the judgment award and securing Daang’s commitment to forego further action, respondents effectively recognized the finality of the award in Daang’s favor. Consequently, the petition before the Court of Appeals was rendered moot, and there was no longer any justiciable controversy for the Supreme Court to resolve. The CA decision was reversed and set aside.